Because it extends the Single Market to the three EFTA States Iceland, Liechtenstein and Norway, the Agreement on the European Economic Area is not an EU external agreement comme les autres. This is particularly salient in the context of the UK withdrawal from the EU. The UK withdrawal will affect the three EFTA States’ citizens, businesses and other stakeholders in a way that is comparable to how it will affect citizens, businesses and other stakeholders from the remaining EU Member States. It is thus critical that the two intertwined processes of leaving the EU (“Brexit”) and consequently the EEA (“Br(EEA)xit”) are closely coordinated if the integrity of the Single Market is to be preserved, in line with EEA rules. The need for coordination between the EU, the UK and the three EFTA States to address the consequences of Brexit for the EEA is a foretaste, albeit specific, of the complex external implications of the UK withdrawal from all other EU external agreements.
Common Market Law Review